Exclusion screening center
Who checks which exclusion list, how often, and where each requirement comes from. Read this as a summary of the cited sources, not legal advice.
Who checks what, and how often
| Who | What to check | How often | Source |
|---|---|---|---|
| State Medicaid agencies | Confirm identity and exclusion status of providers and anyone with an ownership or control interest, agents and managing employees. Check the SSA Death Master File, NPPES, the LEIE and the EPLS (now SAM.gov). | At enrollment and reenrollment. LEIE and EPLS/SAM no less often than monthly. | 42 CFR 455.436 |
| Providers, hospitals, plans and other employers/contractors in Federal health care programs | Check the LEIE for employees, contractors and others before hiring or contracting. | Before hiring/contracting and periodically after. OIG notes that the LEIE is updated monthly, so screening monthly best minimizes potential overpayment and civil monetary penalty (CMP) liability. | OIG Special Advisory Bulletin (May 8, 2013) |
| Medicaid providers (as required by the state) | State Medicaid exclusion/termination list, plus federal lists. OIG's bulletin notes CMS's 2009 State Medicaid Director Letter recommended that states require providers to screen employees and contractors monthly. | Many states expect a monthly check. See your state in the State directory. | OIG Bulletin; Exclia (third-party source for state data) |
| Hospitals (medical staff) | NPDB query (NPDB reports include exclusions and other adverse actions), plus the LEIE and SAM.gov for staff, practitioners and contractors as an employer in Federal health care programs. | NPDB: when a practitioner applies for membership or privileges, and every 2 years. LEIE: before hiring/contracting and periodically after; OIG notes monthly screening best minimizes CMP liability. | 45 CFR 60.17; OIG Bulletin |
| Health plans and CVOs (NCQA-accredited) | NCQA CR 5 (ongoing monitoring): Medicare and Medicaid sanctions, sanctions or limitations on licensure, and Medicare/Medicaid exclusions. NCQA-listed sources include the OIG LEIE, the NPDB, SAM.gov, FSMB and the state Medicaid agency (NCQA made the state agency optional for exclusions as of Oct 15, 2025). Medicaid managed care plans must also follow 42 CFR 438.214 (opens in new tab) and 438.610 (opens in new tab); Medicare Advantage plans must check the Preclusion List (42 CFR 422.222 (opens in new tab)). TRICARE and FEHB contracts can add the DHA and OPM lists. | NCQA: review new sanction and exclusion information at least monthly, or within 30 calendar days of a new alert from a monitoring service. NCQA withdrew its July 2025 “every 30 calendar days” wording on Sept 15, 2025. Plus any contract or accreditor requirements. | NCQA FAQ (CR 5) (opens in new tab); NCQA policy updates (PDF) (opens in new tab); OIG Bulletin |
OIG's bulletin also says no specific statute or regulation requires a provider to check the LEIE. Checking is how organizations avoid employing or contracting with excluded persons and the liability that comes with it.
Related checks on other tabs
Licensure and certification actions are not exclusions, but most files check them too: FSMB DocInfo (physician board actions), Nursys (nurse licenses and discipline), NCCPA (PA certification) and DEA (controlled-substance registration). Federal lists: OIG LEIE, SAM.gov.
Medicare Exclusion Database (MED): CMS’s monthly exclusion file built from OIG data. Access is limited to authorized users (such as CMS contractors and approved organizations) under a data use agreement; most teams use the public LEIE instead.
A simple monthly routine
- Keep one roster of everyone in scope: employed and contracted practitioners, staff, owners and managing employees, and vendors.
- Screen the roster against the OIG LEIE (online search or the monthly download), SAM.gov exclusions, and each state Medicaid exclusion list that applies.
- For a possible LEIE match, confirm identity. OIG says SSN/EIN verification is only available through the online search.
- Save evidence of every search: date, source, the name searched and the result. Our Exclusion Monitoring Log can help.
- Escalate any confirmed match to compliance or legal right away.
The routine above is a general practice suggestion, not a regulatory requirement.